Clifford Chance

The Department of Commerce publishes final rule to ban imports of Chinese or Russian connected vehicles and parts

January 21, 2025

Set to go into effect March 16, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") now Final Rule aims to secure the supply chains of Connected Vehicles from the People's Republic of China ("PRC") and Russia – by prohibiting the import or sale of certain connected vehicle systems designed, developed, manufactured, or supplied by entities with a sufficient nexus to the PRC or Russia. Connected Vehicles utilize specific pieces of hardware and software that allow for both Vehicle Connectivity Systems ("VCS") and Automated Driving Systems ("ADS"). By virtue of permitting external connectivity, these vehicles are allegedly more vulnerable to malicious operators who can access and collect sensitive data and remotely manipulate cars on American roads. Thus, the Department of Commerce has issued the final rule to remedy this loophole in domestic security. Notably, this rule introduces several new requirements and modifications compared to the Notice of Proposed Rulemaking ("NPRM"), which we wrote about previously here.

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